Earlier this year, the New York Department of Financial Services (“DFS”) issued guidance on whistleblowing programs. The guidance broadly defines “whistleblowing” and applies to privately held, state-chartered non-depository institutions licensed in New York, in addition to all other DFS-chartered, licensed and regulated institutions. For a number of reasons, the guidance merits review.
Our discussion will highlight the principles the DFS believes should be accounted for when designing and implementing a whistleblowing program. The discussion will include:
- A summary of the DFS guidance and the entities covered by it
- A comparison to similar federal guidance
- Considerations for designing and implementing a whistleblower program
Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.